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21-1558 Grant Adminstration and Accounting Policy RESOLUTION NO. 21-1558 A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF LONGWOODD, FLORIDA, ADOPTING A GRANT ADMINISTRATION AND ACCOUNTING POLICY;PROVIDING FOR SEVERABILITY, CONFLICTS,AND AN EFFECTIVE DATE. WHEREAS, the City of Longwood (the "City") is vested with home rule authority pursuant to Article VII, Section 2 of the Constitution of the State of Florida and Chapter 166, Florida Statutes, to adopt resolutions; WHEREAS,the City is committed to continuing to improve the City's finance functions,including grants management, budgeting, financial reporting, and procurement; and WHEREAS, as part of this commitment, the City Commission has determined that City of Longwood should have a Grant Administration and Accounting Policy in order to ensure compliance with all applicable laws, regulations, guidance, and grants agreements in the conduct of grant management activities, including pre-award, award, post-award, reporting, reimbursements, and close-out activities; and WHEREAS, the City Commission of the City of Longwood has determined that policies and procedures be established for consistency in handling all city related grant management activities NOW,THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE CITY OF LONGWOOD, FLORIDA, as follows: SECTION 1. The Grant Administration and Accounting Policy attached hereto as Exhibit "A", is hereby adopted. SECTION 2. Severability. If any section, subsection, sentence, clause, phrase, or portion of this Resolution, or application hereof, is for any reason held invalid or unconstitutional by any court or competent jurisdiction, such portion or application shall be deemed a separate, distinct, and independent provision and such holdings shall not affect the validity of the remaining portion thereof to the extent practicable. SECTION 3. Conflicts. To the extend this Resolution or any provision thereof conflict with any previously enacted Resolution of the City of Longwood, then this Resolution shall control only to the extent any such conflict(s) exists. SECTION 4. Effective Date. This Resolution shall take effect immediately upon its adoption. ADOPTED this 3rd day of May 2021, by the City Commission of the City of Longwood, Florida. Resolution No.21-1558 Page 1 of 2 CITY OF LONGWOOD, FLORIDA /2 Richard Drummond, Mayor ATTE �,4 le Lo , , FCRM, City Clerk Approved as to form and legality for the use and reliance by the City of Longwood, only. Daniel W. ey, it Attorney Resolution No.21-1558 Page 2 of 2 Exhibit "A" COMMISSION POLICY CITY OF LONGWOOD SUBJECT: GRANT ADMINISTRATION AND POLICY EFFECTIVE ACCOUNTING POLICY NUMBER DATE PAGE P-204 May 3, 2021 1 of 11 ADOPTED BY: Resolution No. 21-1558 DATED: May 3, 2021 REVISES POLICY: N/A BACKGROUND: At the April 19, 2021 Commission Meeting, the Independent Auditors during their presentation of the City's annual financial statements, made recommendations to the City Commission and City Manager on grant management, and suggested the implementation of policies and procedures. In addition, they recommending having grants activities centralized in the Financial Services Department to allow information to be readily available for reporting to grantors and auditors. PURPOSE: The Grant Administration and Accounting Policy provides guidelines and sets roles and responsibilities for activities surrounding the submittal, implementation, maintenance, reporting and other related duties for grant-funded projects by or on behalf of the City of Longwood. This policy will ensure that: • Federal and State grants are properly authorized by the City; • Grants have been properly budgeted for by the Financial Services Department in order to maintain budgetary controls. • Transactions involving federal and state grants are in accordance with the provisions of the federal Office of Management and Budget Circulars and other federal laws and the Florida Statutes. • Grant transactions are properly identified in the accounting records in order to maintain accounting and reporting controls. • Grant financial reporting requirements are monitored for compliance, and that official accounting records required by grant agreements are maintained to the extent possible in a centralized location. Having grant management activities centralized in the Financial Services Department will ensure that the City's grants management and compliance program is current and effectively fulfills the compliance requirements of the City's administrative policies and external granting agencies, and will limit the City's exposure to grant-related liability by implementing, and maintaining meaningful grant oversight and coordination for the City. Adoption of a Citywide grant policy would bring consistency and control over grants activities. In addition, improvement in controls and record keeping would provide greater quality assurance and improve overall management of grants. P-204—Grant Administration and Accounting Policy Resolution No.21-1558 Page 2 of 11 POLICY: SCOPE The purpose of this Grant Administration and Accounting Policy is to develop, implement,and maintain meaningful grant oversight and coordination for the City, thereby increasing grant-related revenue, limiting the City's exposure to grant-related liability, and improving the efficiency and impact of programs and services funded through grants. The policies and procedures contained herein are intended to foster exceptional stewardship of the public trust through a rigorous adherence to ethical standards associated with grant-related activities.The policies and procedures aim to do the following: • Promote the use of best practices. • Promote sound financial management. • Ensure that grant-related activity is consistent with the City's strategic priorities. • Ensure the integrity of the City's good standing among grant making entities. • Ensure the detection and mitigation of potential grant-related problems before they impact the City. • Promote efficiency and effectiveness in grant funded projects and programs. • Ensure accountability for financial and programmatic elements of grant administration/accountability. This policy provides guidelines to ensure the following: • Federal and state grants are properly authorized by the City. • Grants have been properly budgeted for by the Financial Services Department in order to maintain budgetary controls. • Transactions involving federal and state grants are in accordance with the provisions of the federal Office of Management and Budget Circulars and other federal laws and the Florida Statutes. • Grant transactions are properly identified in the accounting records in order to maintain accounting and reporting controls. • Grant financial reporting requirements are monitored for compliance. • Official accounting records required by grant agreements are maintained to the extent possible in a centralized location. These procedures are developed for the following six main operational categories: • Grant Pre-Application, Application/Request, • Grant Award, • Grant Post Award Management, P-204—Grant Administration and Accounting Policy Resolution No.21-1558 Page 3 of 11 • Grant Accounting and Reporting, • Grant Monitoring, and • Noncompliance Procedures CONFLICTS OF INTEREST Conflicts of interest can damage the reputation and credibility of the City. Further, the appearance of a conflict of interest can be just as damaging to the City's reputation and credibility as an actual conflict. The appearance, as well as the actuality, of any conflict of interest or breach of trust by an official or employee of the City should be avoided. Conflict of interest situations may cover a broad range of matters, and may involve ethical, legal,or other issues. Such situations, if unresolved, may be the cause of damage to the City. City officials and employees should be diligent in the identification of potential conflicts of interest when working in any capacity with any proposed or funded grant involving the City. No officer or employee of the City shall have any interest, financial or otherwise, direct or indirect, or have any arrangement concerning prospective employment that will, or may be reasonably expected to, bias the design, conduct, or reporting of a grant funded project on which he or she is working. It shall be the responsibility of the Project Manager for each particular grant funded project to ensure that in the use of project funds, officials or employees of the City and nongovernmental recipients or sub-recipients shall avoid any action that might result in, or create the appearance of: • Using his or her official position for private gain • Giving preferential treatment to any person or organization • Losing complete independence or impartiality • Making an official decision outside official channels • Affecting adversely public confidence in the grant funded program in particular, and the City in general • Or any other Conflict of Interest outlined per the specific grant agency To strengthen Federal oversight, Mandatory Disclosures require organizations with a Federal award to disclose, "in a timely manner" and in writing to the Federal awarding agency or pass-through entity, "all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award." The guidance specifically adds that an organization's failure to make required disclosures can result in a number of actions, including suspension and debarment. ROLES AND RESPONSIBILITIES The following shall govern responsible parties for activities surrounding the submittal, implementation, maintenance, reporting and other related duties for grant funded projects by or on behalf of the City of P-204—Grant Administration and Accounting Policy Resolution No.21-1558 Page 4 of 11 Longwood. All grants awarded to departments must be included in combined citywide reports under federal and state reporting guidelines. Administrative Authority The City Manager/City Commission/Mayorsigns all grant applications, amendments, modifications, and agreements. However, the City Manager/City Commission/Mayor may delegate authority to sign grant- related documents to the Department Heads, and Project Managers. Financial Services Department Finance/Grants Coordinator The Finance/Grants Coordinator is the primary person responsible for providing city-wide coordination and monitoring of grants. This individual is responsible for ensuring that the City's grants management and compliance program is current and effectively fulfills the compliance requirements of the City's administrative policies and external granting agencies. The Finance/Grants Coordinator is the liaison between the external auditors and the departments. The Finance/Grants Coordinator is responsible for: • Assisting staff with documents preparation as it concerns adhering to grant guidelines, policies, and deadlines. • Tracking grant activity at all stages of the grant cycle. • Reviewing agenda items related to grants prior to submission for Commission agenda. • Receiving a copy of the grant award and maintaining a grant file. • Maintaining Master files of"open" grants. • Maintaining Master files of"closed" grants in accordance with the retention requirements. • Maintaining grant procedures. • Developing and conducting grants administration training on grant management and compliance, if needed. • Updates the Schedule of Expenditures of Federal Awards and State Financial Assistance (SEFA) with information concerning the grant. • Ensuring that departments track and report programmatic and financial grant activity in a timely manner. • Ensure that the grant is established in the financial system. This will include the creation of account numbers for revenues and expenditures. Separate accounts will be created for all budgeted income and expense accounts for each grant. • Providing the proper account codes to the recipient department, so as not to co-mingle funds. • Centralized review of grant report prior to submission. • Work directly with Grants Project Manager to review compliance with Agreement reporting. P-204—Grant Administration and Accounting Policy Resolution No. 21-1558 Page 5 of 11 • Work with the Grants Project Manager, Department Heads, Purchasing and Finance personnel in order to gather all information required to meet Grant Funding requirements, once awarded. • Work with Purchasing Department to ensure all Contracts, Professional Agreements, Invoicing from Vendors meet grant specifications for reporting and reimbursement. • Review and audit required grant documentation necessary to meet grant Funding requirements created by Departments. • Record grant submittals as outstanding receivable and record receipt of reimbursement once received, and notify all interested parties. • Notify the Finance Director of all monitoring visits by a granting agency prior to the visit. • Supply the information needed by the external auditors for the annual single audit. Purchasing Manager The Purchasing Manager will process purchase orders according to the grant agreement, state and federal laws and regulations, and City policy. Grants Project Managers are ultimately responsible to adhere to the stipulations from the approved award/contract to ensure that allowable expenditures are conducted. City Attorney Grant agreements are different from many other contracts in that there is little or no negotiation involved. In the vast majority of circumstances, the City will either sign the agreement or decline the award. Despite the City's lack of bargaining power in this regard, it is nevertheless prudent to conduct a legal review of grant agreements to ensure that all of the terms of the agreement are legally enforceable. Grant agreements will be sent to the City Attorney for review of the terms and conditions. City Departments Department Directors The Department Director has programmatic and fiscal responsibilities for a designated department. He or she is the individual who ensures adequate staff and infrastructure are provided for the appropriate performance of grant award management and supervises staff members identified as key members on grant awards. The Department Director is responsible for: • Ensuring adequate management of programmatic and fiscal aspects of the grant awards. • Appoints a Project/Program Manager to assume the responsibilities of monitoring the grant. • Managing general departmental-level support activities related to grants management. P-204—Grant Administration and Accounting Policy Resolution No.21-1558 Page 6 of 11 • Ensuring any grant agreements are sent to the City Attorney for review. • Approving any proposed programmatic and fiscal changes to the grant. • Reviewing budget amendment requests if they affect commitments by the department. • Ensuring that the department has a retention schedule in place to protect the integrity of the grants records and data collected during the project. • Ensuring that cost sharing dollars are available. • Ensuring the budget is adequate relative to the project scope and its justification is appropriate. • If grant funds have not been totally expended by fiscal year-end, it is the responsibility of the Department Director to notify the Finance Director and/or Finance/Grants Coordinator that budget funds need to be carried forward to the new fiscal year, and to confirm the amounts of such carry-forwards. Carry-forwards of grant funds will be subjected to maximum allowable amounts/percentages based on the grant award agreement. Grants Project Manager The Grants Project Manager is the primary person responsible for the programmatic activities on a project/grant. Although some tasks may be delegated, the Grants Project Manager is the chief accountable person and bears responsibility for the overall administrative and fiscal conduct of the grant award, for meeting the terms and conditions of the award, and for representing the project to the granting agency. The Grants Project Manager is the liaison between the city and the granting agency regarding program performance, operational requirements and monitoring. The Grants Project Manager is responsible for: • Preparing the grant proposal with the assistance of the Finance/Grants Coordinator, with an emphasis on the technical and budgetary components. • Communicates with the funding agency to obtain information concerning the source of funds for the grant. (i.e. CFDA or CSFA number, federal funding percentages, state grants, and aids percentages, etc.) • Forwarding all grant agreements to the Finance/Grants Coordinator for review prior to execution by the proper City officials. • With assistance from the Finance/Grants Coordinator, prepare the Commission agenda item and resolution (if required) requesting City Commission authorization for the Mayor to execute the grant agreement and related documents, if approval of the grant agreement has not been previously authorized. • Requesting that budget be established and approved prior to expenditures being made. • Monitoring the project budget and ensuring the appropriate charging of expenditures to the project grant award. P-204—Grant Administration and Accounting Policy Resolution No.21-1558 Page 7 of 11 • Modifying the project budget, if necessary, in line with the award budget provided by the granting agency. • Notifying the Department Director about changes in project scope and budget. • Appropriately managing the programmatic aspects of the project. • Monitoring expenditures to ensure grant funds are spent in accordance with the approved budget. • Approving all grant expenditures. • Ensuring that expenditures are entered in the financial management system by staff members using the assigned project number. • Working with the Finance/Grants Coordinator to ensure the completeness, accuracy, and timeliness of programmatic and financial reports submitted to the granting agency. • Ensuring the Finance/Grants Coordinator receives copies of any financial reports for review prior to submission to the granting agency. • Ensuring the Finance/Grants Coordinator receives copies of any reports, reimbursements or correspondence with the granting agency. • Ensuring that subcontractors have complied with the appropriate work in a timely manner and in accordance with technical, financial, and other requirements of the award. • Coordinating of any monitoring visits by the grant funding agency. • Notify the Finance/Grants Coordinator prior to monitoring visits by granting agencies and provide with copies of any monitoring reports they may receive and indicate financial records, if any, during monitoring visit. • Adhering to the terms of the grant agreement and policies and notifying the Finance/Grants Coordinator if changes are needed. • Responsible for assembling a "project completion package" as needed. GRANT PRE-APPLICATION All grant proposals/applications must be tracked by the Finance/Grants Coordinator. The Financial Services Department and Finance/Grants Coordinator must be informed of outgoing grant applications at all times. This applies to all grant applications whether they are hard copy, electronic, or prepared by third party administrators. The department preparing a grant application to be submitted on behalf of the City must provide a copy of the application to the Finance/Grants Coordinator in the Financial Services Department. GRANT APPLICATION All Applications/Requests for grant funding are to be tracked by the Grants Project Manager or Department Director. This applies to all types of applications and requests (hard copy, electronic, prepared by third party administrator, support letters and partnership letters). Each department is P-204—Grant Administration and Accounting Policy Resolution No.21-1558 Page 8 of 11 responsible in the preparation of the grant application and provide all required documentation for submittal. All applications must include the program name and Catalog of Federal Domestic Assistance (CFDA) or Catalog of State Financial Assistance (CSFA) number. Under no circumstances should work outlined in the grant application Scope of Services begin prior to the award of the Grant and executed Agreement(s) being completed. It is imperative that communication relating to any proposed applications be relayed to the Finance/Grants Coordinator. This is to ensure that duplicate applications for the same grant are not performed as generally Grantors will not consider any proposal from a municipality if more than one proposal is submitted during the same funding cycle.The City shall not submit multiple grant applications for any one funding announcement or program during the same funding cycle unless explicitly allowed by the Grantor. APPLICATIONS INVOLVING INCREASING STAFFING LEVELS A Grant application that involves funding to increase employee staffing levels requires the approval of the City Manager. GRANT AWARD NOTIFICATION AND ACCEPTANCE Once the award notification has been received by the Grants Project Manager or Department a scanned copy will be sent to the Finance/Grants Coordinator. The recipient department, Finance/Grants Coordinator, and assigned Grants Project Manager are responsible for reviewing the proposed agreement/document to assure that all conditions required by the Grantor can be fulfilled. In the event that the funds awarded by the granting entity are reduced from those requested in the original grant application, the recipient department must ensure that the goals, objectives and evaluation components can still be accomplished and that adequate funding is available to accomplish the intent of the grant. If the review is affirmative, the recipient department will work with the Finance/Grants Coordinator regarding the Agenda Item and all supporting documentation to be placed on the City Commission Agenda. The recipient department must request account codes from Finance/Grants Coordinator (who will coordinate with the Finance Director). Once the account codes are received, a Budget Amendment will be prepared by the recipient department and submitted to the Financial Services Department.All award documents must be forwarded to the Finance/Grants Coordinator. Once the Agreement is accepted by the City Commission and properly executed, it is the department's responsibility to carry out the project and/or activities associated with a grant to their full extent, while adhering to all of the terms and conditions prescribed by the Grantor. Failure to do so increases the City's exposure to legal liability and compromises current and future grant funding. The original (record) copy of the fully executed grant award document will be maintained by the Office of the City Clerk with a file copy to the Financial Services Department and to the initiating Department. P-204—Grant Administration and Accounting Policy Resolution No.21-1558 Page 9 of 11 POST AWARD MANAGEMENT Once the grant funding has been awarded,the work of project implementation begins. The department receiving the award must focus on the implementation, monitoring and evaluation of the grant funded program. Those charged with managing the program must work to ensure that they maintain high standards, achieve stated goals and objectives, meet agreed upon deadline, stay within budget, expend funds as required, comply with the granting entity's terms and conditions, maintain appropriate records, meet financial and programmatic reporting requirements, and communicate results. Oversight of this process is critical to ensuring that the interests and responsibilities of the City are met. Grants management entails the establishment of standard operating procedures and clear, regular communication by the department and Grants Project Manager with the Finance/Grants Coordinator regarding the status of the grant funded project and required communication with the granting entity. GRANT REPORTING Grants awarded to the City typically require that progress and financial reports are submitted to the Grantor. Accurate and timely reporting are critical to maintaining a good relationship with the Grantor and late or inaccurate reports may negatively impact current and/or future funding opportunities. FINANCIAL REPORTING Recipient departments, shall prepare accurate reports as required by the Grantor. Copies of all financial status and final reports prepared for submission to the grantor shall be provided, along with the associated funding account number, to the Finance/Grants Coordinator, for review before submission to the granting agency. The Finance/Grants Coordinator will review for accuracy, and make suggested corrections to the department. Once corrected, Grants Project Manager will submit the official document(s) to the Grantor. Programmatic Reporting Recipient departments shall work with the Finance/Grants Coordinator to prepare accurate progress or other programmatic reports as required by the Grantor. Documents of all progress and other programmatic reports prepared for submission to the Grantor shall be retained by the Grants Program Manager with copy to the Finance/Grants Coordinator. REQUESTS FOR REIMBURSEMENT All requests for reimbursement are to be prepared by Grants Project Manager for review prior to sending to the grantor. All requests for reimbursement should be submitted to Finance/Grants Coordinator at least 15 business days prior to the submission deadline. Finance/Grants Coordinator will reconcile the request to the general ledger to ensure that all eligible expenses are captured in the request for reimbursement. Finance/Grants Coordinator will ensure that an invoice is reflected in the City's financial management system, via Accounts Receivable, so that the reimbursement is posted to the correct general ledger account when received. If a grant reimbursement is received by a recipient department, it should be immediately forwarded to the Financial Services Department for deposit with information including the purpose of the reimbursement and the name of the grant the reimbursement relates to. P-204—Grant Administration and Accounting Policy Resolution No.21-1558 Page 10 of 11 FILE MANAGEMENT It is imperative that file management is consistent for all grants across all departments. Standardized file management protocols allow for a smooth transition during changes in personnel, instill confidence in granting entities during site visits, expedite reviews by the Financial Services Department, and eases the audit process. The Finance/Grants Coordinator will maintain the Master File,which includes the following(if applicable to the project and if required by the awarded Grant): Funder/Legal Documents • Grant application and project proposal • Approved budget • Administrative guidelines and regulations • Official grant award notification (GAN) Budget Records • Copies of all contracts • Copies of purchasing documents • Copies of expenditure/income tracking files • Copies of monthly restricted program grants reconciliation report • Copies of all reimbursement requests • All correspondence with the funder regarding budget • Copies of payroll documents • In-kind or match documentation of expenses File Retention All grant files will be retained for 10 years by the Finance/Grants Coordinator. Grantors may require retention periods in excess of this time period, in which case, the Grantors time period would be followed. If any litigation, claim, negotiation, audit or other action involving records has been started before the expiration of the retention period, records must be retained until completion of the action and resolution of all issues,which arise from it. In this case,the retention period would begin at the close of the action. PERSONS AND AREAS AFFECTED This is a Citywide Policy affecting all persons and Departments who have previously researched, applied for, and/or managed grants. P-204—Grant Administration and Accounting Policy Resolution No.21-1558 Page 11 of 11 GOVERNING LAWS AND REGULATIONS There are specific Administrative Rules and Cost Principle requirements for various agencies. Grantees must demonstrate general familiarity with their applicable administrative requirements, cost principles, and understand how these are relevant to their project. FEDERAL: 1. Single Audit Act of 1984 as amended in 1996. 2. OMB Circular A-133 compliance supplement 2020. 3. Uniform Guidance (2CFR Part 200) 4. Government Auditing Standards issued by the Comptroller General of the United States. STATE: 1. Florida Statues, Chapter 125 2. Florida Administrative Code 3. Rules of the Auditor General, Chapter 10.550, Local Governmental Entity Audits 4. Florida Single Audit Act, Florida Statutes 215.97. NONCOMPLIANCE PROCEDURES The Finance/Grants Coordinator will notify the Grants Project Manager in writing upon noncompliance with the Grants Administration and Accounting Policy and Procedures.The notification will be copied to the Department Director and Finance Director. Compliances failures, whether noted internally by management or through the external audit process, will be addressed immediately by reviewing the reason for the failure with responsible personnel and devising an improved process to encourage compliance in the future.